Basic Initiative Policy

The Codes of Conduct for pursuing the management principles of the Group include “strict compliance with applicable laws and regulations,” positioning compliance as one of our most important management issues.
The Compliance Rules formulated by the Board of Directors define the Group’s overall basic policy, the specific standards that directors, officers and employees must follow, and the Group’s compliance organization structure, creating a compliance system befitting “The Trust Bank.”

Compliance System of SuMi TRUST Holdings

Group Compliance Framework

Each fiscal year, the Board of Directors approves the Compliance Program, which consists of specific practice plans for implementing compliance within the Group, and every quarter the Board of Directors receives reports on the progress, achievement status, and evaluation of the Compliance Program.
SuMi TRUST Holdings has also created a compliance framework for the entire Group, providing guidance to Group companies regarding the formulation of their Compliance Programs, and delivering reports to the Board of Directors on the progress, achievement status, and evaluation of these Compliance Programs.

Initiatives to Foster Compliance Awareness

The Group has created a Compliance Manual containing explanations of laws and regulations that must be followed and actions to be taken in the event of the discovery of compliance infractions, and employees throughout the organization are thoroughly informed regarding its contents.
In addition, SuMi TRUST Holdings is also improving compliance education in the entire Group, through activities such as providing training materials and dispatching instructors for group training tailored to individual roles, etc., planning and implementing discussion-based study sessions, and implementing e-learning on specific themes.
Every fiscal year, we conduct an awareness survey regarding compliance, and strive to identify and address actual issues.

Hotline System

The Group has established a compliance hotline system through which all directors, officers and employees can report violations directly to the Compliance Department and an external attorney’s office. This hotline system enforces the rigorous control of information and protection of privacy to ensure the protection of whistleblowers, and strictly prohibits their adverse treatment.
An accounting hotline system has also been established for the reporting of inappropriate accounting.

Prevention of Money Laundering

The Group has released its “Anti-Money Laundering Compliance Policy,” and made clear its resoluteness in standing up to money laundering.
We have established our global guidelines on AML*1/CFT*2, in order to implement a unified approach to AML measures that includes overseas bases, and the Group is working to enhance its approach toward client protection and the detection of suspicious transactions. Specifically, client management items are confirmed when handling transactions, and when coming across transactions suspected to be related to illegally obtained money or used to finance terrorism, employees immediately report to the person in charge, who notifies the relevant authorities. Moreover, SuMi TRUST Bank has adopted an AML system, which verifies whether any illicit transfers between accounts have taken place.
We require employees at relevant branches and departments to periodically receive training concerning AML, etc. In fiscal year 2017, such training was provided to all employees at the relevant branches and departments.

*1  AML: Anti-Money Laundering

*2  CFT: Combating the Financing of Terrorism

Anti-Money Laundering Compliance Policy

Initiatives to Prevent Bribery

The Group has published its “Anti-Bribery and corruption Compliance Policy,” and under the supervision of the management team, implements anti-bribery and anticorruption programs that include regular assessment of risks related to bribery and corruption, a prior approval system for client entertainment and gift-giving, central management of hiring and trainee acceptance, and making due diligence mandatory before contracts can be concluded for some contract categories.
The Group provides directors, officers and employees with regular training every year, and implements periodic monitoring and testing. Moreover, we have fostered a close-knit collaboration between our overseas bases and local legal offices, especially in countries where the risk of bribery and other forms of corruption is high, and have striven to build systems for responding swiftly and properly.

Anti-Bribery and Corruption Compliance Policy

Response to Antisocial Forces

The Group has declared, both internally and externally, its resolute stance against antisocial forces. We have incorporated a clause to exclude organized crime from all types of transactions, in order to prevent transactions by antisocial forces. In cases in which the counterparty in a transaction is found to be an antisocial force after the commencement of a transaction, we have developed a framework that allows us to take measures in close coordination with the police and other external expert organizations for the eventual cancellation of such a transaction.
From January 2018, we have connected, via the Deposit Insurance Corporation of Japan, to an organized crime group information database operated by the National Police Agency, and check the database before providing new personal loans, etc.
In fiscal year 2017, in order to strengthen awareness of, and systems for, dealing with antisocial forces, we provided directors, officers and employees with training for the prevention of transactions with antisocial forces.

Other Initiatives

The Group strictly manages insider information through its “Rules on Insider Information Management,” which mandate the reporting of insider information that may be obtained during the execution of working duties, and specifies the methods to be used for its management.
Furthermore, with regard to “important information” as defined in the fair disclosure rules enacted in April 2018, we have defined a rule prescribing that in specific circumstances, such important information is classified and handled as important client information under insider trading regulations.
In order to appropriately comply with revisions to laws and regulations, the Compliance Department centrally manages the information on legal and regulatory revisions collected by individual head office departments, shares such information with related departments and Group companies, instructs them regarding the proper response, and manages their response.

Compliance and Conducting Business Activities Fairly

Tax Strategy for UK Entities of SuMi TRUST Group

The SuMi TRUST Group has posted tax strategy for its UK entities pursuant to Schedule 19 “Large businesses: tax strategies and sanctions” of UK Finance Act 2016.

UK Tax Strategy (Updated on March 29, 2018)


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